IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF TEXAS

DALLAS DIVISION

SUSAN CHANG, AS NEXT FRIEND OF §

ALISON CHANG, A MINOR, AND §
JUSTIN HO-WEE WONG, §
§
PLAINTIFFS § CA No. 3:07-cv-1767
§
VS. §
§
VIRGIN MOBILE PTY LTD., §
§
DEFENDANT.
§
§
§

PLAINTIFFS’ UNOPPOSED MOTION TO RESET DEADLINES FOR FED. R. CIV. P.

26(F) CONFERENCE AND SUBMISSION OF A SCHEDULING PROPOSAL

Plaintiffs Susan Chang, as next of friend of Alison Chang (“Alison Chang”) and Justin

Ho-Wee Wong (“Justin Wong”) (collectively “Plaintiffs”) file this unopposed motion to reset the

deadlines for a Fed. R. Civ. P. 26(f) meeting between counsel and the joint submission of a

scheduling proposal, and would show the Court as follows:

Currently pending before the Court is Defendant’s motion to dismiss filed on December

20, 2007. In response to the motion to dismiss, Plaintiffs’ requested the opportunity to conduct

jurisdiction discovery1. On January 3, 2008, the Court entered its order allowing an extension of

time for Plaintiffs to file a response to the motion to dismiss by April 9, 2008.

The parties 26(f) conference deadline is currently set for February 8, 2008, with a

additional deadline to submit a scheduling proposal by February 15, 2008. Inasmuch as the

motion to dismiss may be outcome determinative of the case, Plaintiffs’ respectfully request that

the 26(f) conference be reset to May 26, 2008, which is thirty two (32) days after Defendant has
1
Plaintiffs’ timely propounded discovery on January 17, 2008.

HOUDMS/223999.1
filed its reply brief on its motion to dismiss. Additionally, Plaintiffs request the parties be

permitted to file their scheduling proposal two weeks after the new 26(f) conference deadline

which would be June 9, 2008.

Respectfully submitted,

/s/ Ryan H. Zehl____________________

Ryan H. Zehl
State Bar No. 24047166
Fitts Zehl, LLP
5065 Westheimer Rd., Suite 700
Houston, Texas 77056
(713) 491-6064 (telephone)
(713) 583-1492 (facsimile)
rzehl@fittszehl.com

Mark W. Romney
State Bar No. 17225750
Shannon, Gracey, Ratliff
& Miller, LLP
500 N. Akard Street, Suite 2500
Dallas, Texas 75201
(214) 245-3062 (telephone)
(214) 245-3097 (facsimile)
mromney@shannongracey.com

ATTORNEYS FOR PLAINTIFFS

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Plaintiffs’ Unopposed Motion to Reset Rule 26(f) Conference
 CERTIFICATE OF SERVICE

I hereby certify that on the 1 day of February 2008, I electronically filed the foregoing
document with the Clerk of the Court for the U.S. District Court, Northern District of Texas,
using the Court’s electronic case filing system. The system sent a “Notice of Electronic Filing”
to the following attorneys of record, all of whom have consented to accept this Notice as service
of the document:

Lisa H. Meyerhoff
Baker & McKenzie LLP
2001 Ross Ave.
Dallas, Texas 75201

/s/ Ryan H. Zehl______________________

Ryan H. Zehl

CERTIFICATE OF CONFERENCE

Pursuant to Local Rule 7.1(b), I certify that on February 01, 2008, I had a telephone
conversation with Defendant’s counsel Myall S. Hawkins who stated that Defendant was
unopposed to this Motion.

/s/ Ryan H. Zehl__________

Ryan H. Zehl

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Plaintiffs’ Unopposed Motion to Reset Rule 26(f) Conference